108 T.C. No. 19 UNITED STATES TAX COURT SPRINT CORPORATION AND SUBSIDIARIES, F.K.A. UNITED TELECOMMUNICATIONS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13159-94. Filed April 30, 1997. P, a telephone company, purchased certain telecommunications equipment, digital switches, that required computer software to operate. P claimed investment tax credits (ITC) and depreciation deductions under the accelerated cost recovery system (ACRS) with respect to the total cost of each digital switch, which included the cost of the software used in each switch. R determined that P's expenditures allocable to the software did not qualify for the ITC or depreciation under the ACRS. P treated property known as “drop and block” as 5-year property, as defined in sec. 168(c)(2)(B), I.R.C. R determined that the property was 15-year public utility property. For the years in issue, the property was depreciated under the ACRS. 1. Held: P's expenditures allocable to the software qualify for the ITC and depreciation under thePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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